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Think before providing false or fraudulent documentation.
Think before providing false or fraudulent documentation. The costs could be great.
COVID-19 has up-ended every facet of the healthcare industry. From the mass triage of patients in multiple locations, to resource allocation, to remaining financially viable during a time when elective procedures, treatments and in-patient visits were halted for many.
In searching for solutions to sustaining healthcare operations, many providers turned to the options available through the Coronavirus Aid, Relief, and Economic Security (CARES) Act, including the Paycheck Protection Program (“PPP”) loans, which may be forgiven if two conditions are met, and the Provider Relief Fund (“PRF”). And, as the title of this article suggests, “the devil is in the details”, which has been interpreted to mean “a catch hidden in the details.”
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Indeed, there are “catches” in both the PPP loans and the PRF monies. First, let’s address the PPP loans. Here are some key items, which can be “catches” and land persons in hot water:
Now, assuming a provider, say a multi-specialty practice, applied for and received a PPP loan, provided truthful information, used it as required and documented how the funds were utilized to substantiate the allocation of the funds in the event of an audit. How do the PPP loan proceeds coincide with the funds received from the PRF?
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The items listed here are just some of the “catches” that providers accepting funds need to be aware of. It is imperative to seek appropriate counsel and advice to understand all of the legal and financial nuances. The consequences for falsifying the documentation or the attestation can include criminal and civil liability. Just ask the two men from Rhode Island who were charged in the District of Rhode Island with allegedly filing false and fraudulent applications for PPP loans. (hyperlink this - https://www.justice.gov/opa/pr/two-charged-rhode-island-stimulus-fraud)
Rachel V. Rose, JD, MBA, advises clients on compliance and transactions in healthcare, cybersecurity, corporate and securities law, while representing plaintiffs in False Claims Act and Dodd-Frank whistleblower cases. She also teaches bioethics at Baylor College of Medicine in Houston. Rachel can be reached through her website, www.rvrose.com.